Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stored?

[MMM2010]

This topic has come up before but it looks like it has been a few years back. I also have a new spin on it. We have an internal procedure which allows for certain equipment to have the calibration start date extended upon issuing of the equipment in service. Examples are Pressure gages, Dew Point Meters, flukes..etc. The purpose is to compensate for long lead times for calibration by outside 3rd parties. Like many posts here, we keep spares meters or gages which we issue when expired meters or gages are pulled out of service. We store these in locked and controlled environments, and the type of equipment should not change or degrade during storage. This has been no issue as an AS 9100 registered organization.

However, we are now delving into NADCAP, and specifically NADCAP for heat treat and MTL testing (ISO 17025) in support of heat treat. I am new to NADCAP and not an expert. We have an M&P Engineer who has worked in a NADCAP enviornement who insists that this practice is not allowed by NADCAP. According to our new expert, NADCAP AC7101, AC7102, AC7006, and ISO 17025 all supercede AS9100. It is their interpretation that the requirements are more stringent than AS9100, and as a result the practice of extending the start date for calibrated equipment is strictly prohibitied per ISO 17025 and the NADCAP standards.

Needless to say my inexperience with NADCAP requirements, and this individuals interpretation of NADCAP requirements, are in conflict with our established AS9100 QMS.

We are really struggling with how to roll all of these new NADCAP and ISO 17025 requirements into our exisitng AS9100 established organization. My fear is that this individual is basically interpreting a need to have parallel quality management systems for AS9100, ISO 17025, and NADCAP. It does not make since to me that this is the intent of all these standards.

I am hoping the mebers of this community can give me some insight on the acceptability of this practice in terms of NADCAP/17025.
I do plan on obtaining outside training to bridge my lack of experience, if anyone has a good recommendation on where to obtain that training/education in the Los Angeles area it would be appreciated.

 

[Stijloor]

Re: Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stor

A Quick Bump!

Can someone help?

Thank you very much!!

 

[andygr]

Re: Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stor

M&P Engineer who has worked in a NADCAP enviornement who insists that this practice is not allowed by NADCAP. According to our new expert, NADCAP AC7101, AC7102, AC7006, and ISO 17025 all supercede AS9100. It is their interpretation that the requirements are more stringent than AS9100, and as a result the practice of extending the start date for calibrated equipment is strictly prohibitied per ISO 17025 and the NADCAP standards.

You should ask your "expert" to show you where in the AC documents or even the ISO that this is stated. Nadcap does not get into in any of this type of detail.
What your expert might be "interperting" is in table 1 AMS 2750 to say that this practice is not allowed. No where in this document does it state this.
IF your storage procedures are clearly defined and followed and the historical calibration data shows that they are approprate there is no reason that you can not follow the practice you have in place as long as it is a documented part of your calibration procedure. What you will not be able to sell is if you "cycle" a unit in and out of an active status. Once in use the unit starts its calibration cycle.

Since you are looking to get NADCAP approval for HT I can recomend the PRI course Introduction to Pyrometry which is in Torrance, CA 14-15 February 2013
here is a link
https://www.equalearn.com/learncenter.asp?id=178409

 

[Mikishots]

Re: Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stor

This topic has come up before but it looks like it has been a few years back. I also have a new spin on it. We have an internal procedure which allows for certain equipment to have the calibration start date extended upon issuing of the equipment in service. Examples are Pressure gages, Dew Point Meters, flukes..etc. The purpose is to compensate for long lead times for calibration by outside 3rd parties. Like many posts here, we keep spares meters or gages which we issue when expired meters or gages are pulled out of service. We store these in locked and controlled environments, and the type of equipment should not change or degrade during storage. This has been no issue as an AS 9100 registered organization.

However, we are now delving into NADCAP, and specifically NADCAP for heat treat and MTL testing (ISO 17025) in support of heat treat. I am new to NADCAP and not an expert. We have an M&P Engineer who has worked in a NADCAP enviornement who insists that this practice is not allowed by NADCAP. According to our new expert, NADCAP AC7101, AC7102, AC7006, and ISO 17025 all supercede AS9100. It is their interpretation that the requirements are more stringent than AS9100, and as a result the practice of extending the start date for calibrated equipment is strictly prohibitied per ISO 17025 and the NADCAP standards.

Needless to say my inexperience with NADCAP requirements, and this individuals interpretation of NADCAP requirements, are in conflict with our established AS9100 QMS.

We are really struggling with how to roll all of these new NADCAP and ISO 17025 requirements into our exisitng AS9100 established organization. My fear is that this individual is basically interpreting a need to have parallel quality management systems for AS9100, ISO 17025, and NADCAP. It does not make since to me that this is the intent of all these standards.

I am hoping the mebers of this community can give me some insight on the acceptability of this practice in terms of NADCAP/17025.
I do plan on obtaining outside training to bridge my lack of experience, if anyone has a good recommendation on where to obtain that training/education in the Los Angeles area it would be appreciated.

AS9100C states that you shall define the frequency of checks. It goes on again to say that you shall calibrate or verify (or both) at specified intervals.

A device that has not been calibrated or verified for longer than the specified time frame is considered unacceptable for use in providing evidence of conformity of product to determined requirements.

There is no ambiguity or conflicting requirements; I'm in agreement with your colleague. NADCAP/ISO 17025 certainly do not have requirements that allow relaxation of the points made in AS9100C.

 

[andygr]

Re: Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stor

"AS9100C states that you shall define the frequency of checks. It goes on again to say that you shall calibrate or verify (or both) at specified intervals."

What it does says is:
The organization shall maintain a register of the monitoring and measuring equipment and define the process employed for their calibration/verification including details of equipment type, unique identification, location,
frequency of checks, check method and acceptance criteria.

a) be calibrated or verified, or both, at specified intervals, or prior to use, against measurement standards traceable tointernational or national measurement standards; where no such standards exist, the basis used for calibration or verification shall be recorded (see 4.2.4);

e) be protected from damage and deterioration during handling, maintenance and storage.

ISO 17025 states
5.10.4.4 A calibration certificate (or calibration label) shall not contain any recommendation on the calibration interval except where this has been agreed with the customer. This requirement may be superseded by legal regulations.

No where is is stated that you can not properly store a calibrated piece of equipment and start it calibration cycle at the point it is put into service. This condition is solely based on the specific instrument and its stability in the conditions it it exposed to.
You may need to maintain a calibration cycle even if a unit is in storage based on data but no where is it stated that you have to.

 

[Mikishots]

Re: Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stor

"AS9100C states that you shall define the frequency of checks. It goes on again to say that you shall calibrate or verify (or both) at specified intervals."

What it does says is:
The organization shall maintain a register of the monitoring and measuring equipment and define the process employed for their calibration/verification including details of equipment type, unique identification, location,
frequency of checks, check method and acceptance criteria.

a) be calibrated or verified, or both, at specified intervals, or prior to use, against measurement standards traceable tointernational or national measurement standards; where no such standards exist, the basis used for calibration or verification shall be recorded (see 4.2.4);

e) be protected from damage and deterioration during handling, maintenance and storage.

ISO 17025 states
5.10.4.4 A calibration certificate (or calibration label) shall not contain any recommendation on the calibration interval except where this has been agreed with the customer. This requirement may be superseded by legal regulations.

No where is is stated that you can not properly store a calibrated piece of equipment and start it calibration cycle at the point it is put into service. This condition is solely based on the specific instrument and its stability in the conditions it it exposed to.
You may need to maintain a calibration cycle even if a unit is in storage based on data but no where is it stated that you have to.

As I stated: A device that has not been calibrated or verified for longer than the specified time frame is considered unacceptable for use in providing evidence of conformity of product to determined requirements.

Now, if you calibrate that nonconforming tool prior to use, it's no longer unacceptable, is it?

And all the 17025 clause is getting at is what's entered on the cert or sticker; you can enter a cal date, but you can't enter a next cal due date (with exceptions); the next cal date is entirely dependent on use, the organization, possible tool failure etc.

 

[dv8shane]

Re: Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stor

We have an internal procedure which allows for certain equipment to have the calibration start date extended upon issuing of the equipment in service. Examples are Pressure gages, Dew Point Meters, flukes..etc.

This works if you are not following an assigned standard for pyrometry such as AMS2750D for customer requirements. In this case it becomes a requirement to a specific standard, the intervals and allowed extensions are very specific. There are many items detailed in the standard that are not requirements of 17025 or AS9100 but are required by AMS2750D.

We have an M&P Engineer who has worked in a NADCAP enviornement who insists that this practice is not allowed by NADCAP. According to our new expert, NADCAP AC7101, AC7102, AC7006, and ISO 17025 all supercede AS9100. It is their interpretation that the requirements are more stringent than AS9100, and as a result the practice of extending the start date for calibrated equipment is strictly prohibitied per ISO 17025 and the NADCAP standards.

Under 17025 you can extend the calibration interval with sufficient proof and documentation. Under AMS2750D the standard NADCAP uses as a base line there are specific amounts of time that you may increase the interval of testing or calibration.

We are really struggling with how to roll all of these new NADCAP and ISO 17025 requirements into our exisitng AS9100 established organization. My fear is that this individual is basically interpreting a need to have parallel quality management systems for AS9100, ISO 17025, and NADCAP. It does not make since to me that this is the intent of all these standards.

Yes you may have to do this in order to comply with your customer requirements. I currently operate under a QMS with AS9100 and ISO17025 integrated as the basis and do pyrometry under AMS2750D per customer requirements

 

[Jerry Eldred]

Re: Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stor

First of all, I'm not an expert in this topic.

Just wanted to share a thought and associated question....

What about a case where an interval is a "usage" interval? That is, define the calibration due date based on number of months/weeks/etc. of usage. This would certainly have to be supported with proper historical data. We have customers who use usage intervals on high temperature thermocouple sensors, as the degradation in performance is caused by exposure to the high temperatures.

Just a thought to see what the consensus is in this.

 

[BradM]

Re: Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stor

I would consider defining the calibration interval as the time which the device is actually in use. As long as you aren't having calibration failures, I would think that is acceptable.

Do you have the ability to verify any of these instruments in-house?

I would clarify this issue with your NADCAP auditor as to your approach and why you wish to approach it that way.

AMS 2750 is a very inflexible document, and IMHO, not a good standard for enforcing calibration requirements. But... as long as one wants to play in the NADCAP industry, it is the law.

 

[TrivialSublime]

Re: Does 17025/NADCAP allow deferring Calibration Start Dates on Gages which are Stor

Hello MMM2010,
We are NADCAP accredited for Heat Treat. We have what is called a 'captive' Heat Treat shop.
We also have written into our system the set a due date upon issuance of calibrated equipment since Z540 has no requirement against it and ISO 17025 only mentions it as a customer requirement. This existed long before our company went to NADCAP (2004)
That being said, when it comes to instrumentation, AMS 2750D is quite clear (Table 3)as well as a couple of other sections, 3.2.6.2 which states among other things that a " due date of the next calibration" is required on a calibration report.
Keep in mind quite a few of the primes defer to AMS 2750 as the governing pyrometry specification when it comes to their heat treats specs. The exception I deal with is Boeing which has either BAC 5621 or DPS 1.700 as pyrometry specs that you must be complaint to if you are doing heat treating for Boeing.
If you do anything like BAC 5602 I strongly urge you to make sure you are compliant to BAC 5621 and also that you read very closely specific and implied requirements in that document concerning TUS.
As someone said in another post, if you are working in the NADCAP universe which the primes have created for us (yay, not!) you must be complaint to AMS 2750 as a minimum. And whoa be those that try to argue a logical interpretation of a specification when it comes to a NADCAP Staff Engineer, you will unfortunately lose...
Sign me a veteran of the NADCAP accreditation wars (including multiple Purple Hearts)